Blogs from April 2016

No one enjoys going through the audit process. Yet the reality is that most medium and large sized businesses in the US are likely to have their tax positions audited by the IRS sooner or later. And for companies that have international affiliates, that will inevitably entail an examination of their transfer pricing practices and documentation.
Transfer pricing has been cited by IRS officials for years as one of their most important enforcement priorities. But as a direct result of BEPS (the OECD’s Base Erosion Profit Shifting project), tax authorities around the world are actively engaged in the process of revising and tightening their expectations and requirements with respect to transfer pricing. The prospect of thorough and detailed examinations of taxpayers’ transfer pricing positions is growing sharper every day, including here in the US.
Fortunately, an important document exists that can help taxpayers be better prepared for the eventuality of their transfer pricing being audited by the IRS...